Digital imprints were introduced for the whole of the UK in the Elections Act 2022, coming into force in November 2023, but digital imprints have been required in Scotland since the 2014 Independence referendum and in all devolved Scottish elections since 2020.[1]
ERS has long advocated for the extension of the imprint regime to digital election material. Digital imprints, stating who has paid for and promoted content, are aimed at enhancing transparency about who is behind online campaign material. Recognition of the need for voters to know who is trying to influence their vote online, and to be able to hold those seeking to persuade them to account after the election was a key driver of the imprint scheme. Imprints were also considered useful for the Electoral Commission in its monitoring and enforcement work.
Imprints are designed to inform the public about who is behind a campaign ad that they see online, such as on social media, websites and videos. The current rules apply to paid-for political material and some ‘organic’ content (if it is produced by a regulated participant such as a political party, candidate or third-party campaigner). ‘Political material’ is material ‘whose sole or primary purpose can reasonably be regarded as intended to influence the public, or any section of the public, to give support to or withhold support’[2] from political parties, candidates or referendum outcomes amongst others. The rules do not apply to private individuals posting content.
The Representation of the People Bill seeks to extend the imprint rules to organic material produced by third-party campaigns that are not registered with the Electoral Commission (because they are spending under the threshold for registration) but that are still producing campaigning material.
The UK-wide imprints regime applied first to the 2024 local elections and subsequent 2024 General Election. Having been in place for these elections we have initial data on how the scheme operates in practice.
Compliance
The imprint rules are enforced by the Electoral Commission and police. Failing to comply is an offence under section 48(1) of the Elections Act 2022.
Research looking at compliance with the statutory guidance on digital imprints during the 2024 General Election finds that there is significant variety in application.[3] The research finds that 68.9% of campaign material which required an imprint carried some form of imprint, but only 5.7% of material met all of the requirements as set out by the Electoral Commission (that it was present within the material, visible and legible). Half of the material which had some form of imprint, had one that was accessible (if you click through) but not included within the main material, and 37.7% of imprints were not legible (mostly due to tiny text).
What imprints can do… and what they cannot
Imprints can provide voters with basic information about the source of what they see and an indication of whether what they are viewing is campaign advertising. This can be useful in helping voters identify ‘native advertising’ techniques where ads are made to look like journalism or individual posts providing voters with a way to spot content designed to sway their opinion.[4] As currently designed, imprints enable voters to know if the material is designed and promoted to influence the outcome of an election.
However, there are limitations to what imprints reveal to voters about the source of the content they see. Campaign material may have partisan or financial links which are not revealed by the imprint (even if it complies with the rules). For imprints, the ‘source’ is the organisation or person directly responsible for placing/distributing the material, but this source information does not necessarily reveal other affiliations, partisan goals or financial backers.
A lack of clarity on the ‘true’ source of material in this way can be used to gain advantage. Studies of the effect of badging and imprints on campaign material show that material which is labelled as non-partisan but nevertheless is making partisan claims (what the researchers term ‘clandestine campaigning’), can gain an advantage because it by-passes viewers partisan cues.[5] Whilst these observed effects are smaller when comparing ‘clandestine campaigning’ material to those with an imprint, than when it is compared to material ‘badged’ with party labels, it does suggest that the effects of the imprint regime should be monitored closely.
Comprehensive source information would ideally enable voters to establish the independence of the campaign to understand its motivations and therefore credibility.
Likewise, imprints cannot tell voters about the veracity of the claims they see online and nor can they prove the trustworthiness of the campaigner – only that the campaigner has complied with the electoral law in this area. For third parties who are registered with the Electoral Commission, the imprint would signify that the organisation is subject to further disclosure requirements on donations and spending, and would also provide voters with a route to finding out more about those campaigns via the Electoral Commission. This further monitoring may provide a shortcut to establishing a level of trustworthiness for voters (though this would require voters to have knowledge of campaign regulations) but would not apply in the case of unregistered campaigns.
Imprints cannot deal with wider issues of disinformation and the potential for electoral information incidents for which much wider measures are needed.[6]
Ad libraries
An online ad repository or ‘library’ would assist with improving transparency around digital campaigning. This would allow both the public and regulators to view ads across all platforms and help to identify campaigns that are designed to mislead the audience about their source.
The Committee on Standards in Public Life, Committee on Democracy and Digital Technology, and many campaigners have called for a comprehensive advert repository.[7] Whilst some platforms have provided ad libraries voluntarily, the information is of varying accuracy, and not all platforms provide this information.
A comprehensive public repository should capture at a minimum: the material, who has paid for the ads, exactly how much was spent, the target audience and methods for targeting. This could draw upon EU regulations which established a public ad library (Regulation (EU) 2024/900) or the Latvian model which requires platform companies to submit contract information, make prices public and keep a record of all adverts.[8]
End Notes
[1] The original Scottish imprint regime differed from the UK Elections Act provisions but was replaced in The Scottish Elections (Representation and Reform) Act 2025 with rules that mirror the UK-wide ones in all but one aspect. The new Scottish regulations extend imprint requirements to unpaid for (organic) digital material that is promoted by third-party campaign groups that are not regulated non-party campaigners (e.g. campaigners not registered with the Electoral Commission).
[2] Electoral Commission, Statutory Guidance: https://www.electoralcommission.org.uk/statutory-guidance-digital-imprints/what-sort-material-requires-imprint/political-material
[3] Dommett, K., Luke, S., Gordon, H., (2025) Making elections more transparent? Lessons from the Implementation of digital imprints at the 2024 UK General Election, Policy Studies, published online: 03 April 2025. https://www.tandfonline.com/doi/full/10.1080/01442872.2025.2482869
[4] Electoral Reform Society, Gordon, H., Digital imprints: what are they and why are they useful? https://electoral-reform.org.uk/digital-imprints-what-are-they-and-why-are-they-useful/
[5] Stafford, T., Gordon, H., Zhu, J., & Dommett, K. (2025). Online political adverts: The effect of disclosures and opportunities for clandestine campaigning. Political Psychology, 46, 722–748. https://doi.org/10.1111/pops.13034
[6] See for example Electoral Reform Society, Democracy in the Dark: Digital Campaigning in the 2019 General Election and Beyond, 2020. Available at: https://electoral-reform.org.uk/latest-news-and-research/publications/democracy-in-the-dark-digital-campaigning-in-the-2019-general-election-and-beyond/#sub-section-5 and, DEMOS, Epistemic Security Briefing, 2026. Available at: https://demos.co.uk/wp-content/uploads/2026/01/Epistemic-Security-Brieifing_The-Elections-bill_2026.pdf
[7] See for example Full Fact House of Lords Select Committee on Democracy and Digital Technologies, Report of Session 2019–21, ‘Digital Technology and the Resurrection of Trust https://committees.parliament.uk/publications/1634/documents/17731/default/
[8] International IDEA, Regulating Online Campaign Finance: Case Study on Latvia 2022. Available at: https://www.idea.int/news/how-successfully-regulate-online-campaign-finance-some-lessons-latvia